Starship's first Starlinks: what a launch looks like in the regulatory record

SpaceX's Starship put 26 Starlink satellites in orbit on 28 September 2026. Where that launch appears in the public record, which FCC clock it counts against, and what the record cannot tell you.

Published 6 October 2026

A launch is not a filing

On 28 September 2026, SpaceX's Starship reached orbit for the first time and deployed 26 Starlink satellites. It was one of the most watched launches of the year. It also created no regulatory filing at all.

A launch files nothing with the Federal Communications Commission. The licensee reports on milestones, not launches: it certifies a milestone once it has been met, and the Commission then publishes its finding (see our guide to FCC milestones). So on the day of the launch, and for some time after, the FCC record looks exactly as it did the day before. Here is where the launch does appear, and what it takes to connect it to the deadlines it counts towards.

Where it shows up: the satellite catalog

The public record of what is in orbit is the satellite catalog. By 1 October 2026 it listed all 26 satellites, as objects 2026-225A to 2026-225AB, named STARLINK- and a number (CelesTrak's record of the launch). They were in a low orbit, around 270 kilometres up and inclined about 30 degrees to the equator, as the catalog recorded them on 1 October 2026.

The catalog's owner field says US. It names a country, never a company. Our pipeline reads the catalog every morning, and connects objects to an operator only by constellation names we have checked one by one: STARLINK is SpaceX's.

Which licence? The record does not say

SpaceX holds more than one Starlink authorization: the first-generation system granted in 2018, and the second generation granted in stages since 2022. The catalog records a satellite, not the licence it flies under, and nothing in the public record we read ties these 26 satellites to one authorization.

What the record does show is intent. In the application the FCC acted on in January 2026, SpaceX asked to operate a shell at 32 degrees of inclination to accommodate Starship launches from Starbase, as the Commission's Order recounts (DA 26-36). That is a request described in an Order, not a statement about these satellites, and we treat it as exactly that.

The clock they most likely count against

The second-generation licence is ICFS file SAT-LOA-20200526-00055. The FCC's registry gives it a grant date of 9 January 2026, the date of its most recent action. Count the six- and nine-year milestones of 47 CFR 25.164 from that and you get 2032 and 2035.

That is not when the Commission's clock started. The Order that first granted the licence, FCC 22-91, released on 1 December 2022, sets the dates itself in paragraph 137:

• the surety bond, no later than 31 December 2022;
• half of the authorised satellites launched and operating no later than 1 December 2028;
• the rest no later than 1 December 2031.

The bond date is what settles it. A bond is due 30 days after the grant, and 31 December 2022 is 30 days after 1 December 2022, the same grant date that produces both milestone dates. Two dates in one document agree on one grant, so the Order's dates are the ones we publish, with the reconciliation shown.

The January 2026 Order added a second tranche of satellites to the same licence. Where the Commission grants a system in stages, 25.164 applies the earliest of the milestone schedules to the whole system, so the 2028 date is the one that governs.

When does a milestone count as met?

Not when satellites launch, and not when we count them. The FCC never records individual launches. What it records is a milestone, in three steps:

1. The licensee certifies. Once enough satellites are up, and no later than 15 days after the milestone date, the licensee tells the Commission it has met the milestone, or that it has not (47 CFR 25.164(f)). For the second-generation licence, that is due by 16 December 2028 at the latest.
2. The Commission publishes its finding. The FCC's satellite division announces that the milestone was met in its weekly public notice of actions taken.
3. We read that notice. Orbital Docket reads those notices every morning, and the finding is what moves a milestone to satisfied, with the Commission's sentence quoted beside it.

So nothing is missing from the record today: the second-generation milestone is not due until 2028, and the Commission has nothing to announce yet. For SpaceX's first-generation system, all three steps have already happened. The Commission announced its finding on 9 September 2022 (DA 22-933):

The Satellite Programs and Policy Division has determined that Space Exploration Holdings, LLC (SpaceX) has met the launch and begin operations milestone associated with its grant of authority to construct, deploy, and operate a constellation of non-geostationary orbit space stations (call signs S2983/3018), and may release the bond associated with this authorization.

That sentence, and not a launch count, is what moved SpaceX's first-generation milestone to satisfied in Orbital Docket. Until a finding like it is published for the second generation, its 2028 milestone stays a deadline, however many satellites go up, and the satellite catalog is the only public record of launches like this one.

What this looks like in Orbital Docket

On the record for this licence, the launch appears in three places, each with its source:

1. The date. 1 December 2028, labelled as the Order's own date, with the bond deadline that corroborates it and the date the registry would have given instead.
2. The satellite catalog. What the catalog shows SpaceX has launched since the 2022 grant, with this launch as the most recent, and a plain statement that the count is for the operator, not the licence.
3. The Commission's determination, quoted, where one exists. For the first-generation milestone it does; for the second generation, not yet.

None of the three is our opinion. Each is a document you can open.

This note describes public records and how Orbital Docket reads them. It is regulatory research that shows its working, not legal advice.